Case Explained: WINSTON LLOYD HAYLES v. U.S. ATTORNEY GENERAL

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-06-22 The Eleventh Circuit dismissed Winston Lloyd Hayles’s petition for judicial review due to a lack of subject matter jurisdiction. The court held that under the interlocking statutes governing immigration appeals—specifically the Illegal Immigration Reform and Immigrant Responsibility Act, the Foreign Affairs Reform and Restructuring Act, and the REAL ID Act—a court of appeals lacks jurisdiction to review a denial of relief under the Convention Against Torture (CAT) unless the petition simultaneously challenges a final order of removal. The court reasoned that while CAT determinations are “questions of law and fact” arising from removal actions subject to judicial review, such review is exclusively channeled through a petition for review of a final removal order; a petition challenging only the CAT denial, without challenging the underlying removal order, falls outside the court’s statutory authority. The court further determined that Hayles’s pro se petition failed to challenge his final administrative removal order issued on July 13, 2023. Although the court applies a liberal construction to pro se petitions, it found that the document explicitly referenced only the Board of Immigration Appeals’ November 8, 2023 decision denying CAT relief and contained no arguments or references regarding the validity of the removal order itself. Additionally, the court rejected Hayles’s argument that his appellate briefing could amend the petition to include a challenge to the removal order, noting that jurisdiction is defined by the petition filed, not by subsequent briefs, and any proposed amendment would be frivolous as it lacked merit. As a practical consequence, the petition for review was dismissed without addressing the merits of Hayles’s claims regarding CAT eligibility or procedural due process violations. The dismissal affirms the Board of Immigration Appeals’ denial of CAT relief and leaves the final administrative removal order in effect. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.